COVID19 Assessing and controlling risks at work
At the end of March we are several weeks into the COVID 19 pandemic with many more to go. Some advice is clear, such as wash your hands thoroughly and often, but other advice is less clear, and nothing like so easy to follow. In fact, even frequent hand-washing isn’t easy if soap (or other detergent) and water aren’t readily available - not to mention hand-drying facilities. Information is available, but it changes, and it isn't consistent across all sources, and there is also the problem of fake\false information that can find its way into the open.
So what tools and techniques do we have available to us for deciding what we must do?
Well, we have instructions from Government to avoid unnecessary journeys and to work from home where possible. But working from home isn’t possible for some people and is not at all what some people are being asked to do. This includes checkout operators, refuse collectors, delivery drivers, postmen/women, police officers, and construction and maintenance workers, as well as all those directly involved in the healthcare sector. It would be only too easy to overlook these workers, and they deserve to be made as safe as possible.
We know some things about the COVID19 virus and the disease it produces in humans but not as much as we would like. In particular, we don’t know how to cure it, though the medical staff who treat patients are fast becoming experts in caring for these patients while they recover. Something we do know is that the virus falls within the scope of COSHH as a biological agent hazardous to health, and in this respect, it should be possible to use the techniques of the so-called ‘BIO-COSHH’ assessment to reach some sort of evaluation of risk, bearing in mind that unlike hazardous chemicals, the virus does not come with an MSDS, and the world is effectively a research laboratory
Those familiar with COSHH assessment will appreciate that complete separation from the source of contamination (i.e. potentially any other person who is not actually known to be uninfected – which is a problem in itself until widespread testing ins available) is the most effective control measure we have, hence the advice from the Government. Identification of persons most at risk, such as the 1.5 million highly vulnerable people who are to maintain effective lockdown, is a recognised part of any risk assessment. But returning to the groups of workers mentioned before, who are not taking part in lockdown but are at work, we need to be able to evaluate the risk and put in place effective and appropriate controls, in fact the Law requires it.
Some commentators have suggested that the virus could be categorised under containment level 3 (CL3). The COSHH ACoP schedule 3 part ii gives details of how these measures could be applied in a laboratory or process setting, though we are thinking about how they could be applied in the setting of the jobs mentioned earlier. To the best of current knowledge, we believe that the COVID19 virus is readily transmissible, the virus being spread by droplets, usually ejected by coughing or sneezing, or even exhaling, which we either inhale or pick up on our skin, particularly hands, and then transfer to our mucous membranes - mouth, nose, eyes. It can produce a disease in some people that is potentially fatal, with a fatality rate somewhat greater than that of seasonal flu. The disease affects different people very differently (seemingly men more than women) with some experiencing very mild symptoms and others fatal effects. For a young and fit workforce the harm rating could be medium, though not all our workforce neatly fits this description, (possibly 16 on the conventional 1 to 25 grid) and we need to consider that the level of exposure may affect both the chances of catching the disease and the severity of its outcome. We have seen that a number of fit and young frontline medical staff have died from the disease, seemingly related to repeated and intense exposure from patients. Essentially we have to treat this risk as medium to high, and work our way through the COSHH hierarchy of control as systematically as possible.
Elimination – lockdown/isolation is the strongest measure but not applicable if we are interacting with any people in any way, and even at a safe distance – i.e. in the workplace.
Engineering controls such as ventilation may be helpful though this may mean general ventilation in effect – possibly working in the open. LEV, while much more effective, is not generally relevant to the work we are considering.
Management controls are the ones we have to try hardest with. We have the possibility of separation in time, e.g. staggered shifts, which may enable separation in space.
Separation in space relates to transmission as the virus is believed to be able to travel up to two metres from an infected person when they cough or sneeze ( maybe more). Like so many simple but effective control measures - like reducing traffic speed, this simple control is the one we are having the biggest problems with because it will often depend on human behaviour. We have encountered this issue many times before. The measures that have been most effective always seem to be strong leadership – particularly by example, clear instructions, - including signage, and effective supervision – with appropriate intervention, and we can clearly see where these are being deployed and where they are not.
PPE is somewhat controversial because experts have said masks may not be effective and may give a false sense of security, though where the effectiveness of other measures (see above) may be in question, it seems like a good idea, particularly gloves. The main problems with PPE for our workers are about suitability, availability, cleanliness, and consistency of use, so nothing new really. Safe systems which are reliant on PPE fail as soon as it is not fully effective.
Hygiene is one of our most effective options, though regrettably, research has repeatedly shown that hand-washing is not one of the British Public’s outstanding characteristics, and this has to change for our workforce. Significantly, women are better at hand-washing than men, and are also less susceptible to the virus – fewer die. We are back again to behavioural change, and of course, provision of appropriate materiel. Ensuring that the working environment is clean is certainly something we could do, with the use of regular disinfection using biocides or where appropriate, UVC systems.
While emergency measures, such as might be necessary in the event of a spillage or release of a hazardous substance, do not readily apply in this situation, a swift and appropriate response when workers report that they are experiencing symptoms is essential, and this needs to be thought through in advance.
Self-monitoring has always been part of our COSHH control regime, and this has required the effects of exposure to a hazardous substance to be understood by all users. This in turn requires effective communication and provision of relevant information.
So, given that every situation will be different, we have some common themes, and these are the same controls we would apply for the use of a hazardous substance, which comes with the benefit of a Materials Safety Data Sheet, which of course COVID 19 does not. All in all, there is nothing about managing this situation which should be beyond the scope of good mangers.
Strong leadership – being prepared to set an example and be out in front, and to keep up to date with the changing situation.
Confident and informed supervision
Identify persons at risk - self isolation, effective human resource management
Eliminate contact where possible – e.g. contactless/remote payment, click and collect
Engineering controls such as ventilation – selecting appropriate location, screens
Separation in space – requiring good management and above all supervision
Job rotation – requiring resourceful management and worker co-operation
PPE – maybe appropriate, for specific situations, following risk assessment
Hygiene – extra resources, training, and cultural change
Information – reminders to all about all the information they need, self-monitoring, actions to take
Consultation – ensuring a two-way flow of information
Discipline – for when all else fails and the measures are being undermined, and a result of confident supervision and strong leadership
So, a list for management, but so far little mention of the workforce, and yet without the active co-operation of the workforce none of this will really work. Obviously, the engagement of the workforce is essential, so we will need to hold briefings and toolbox talks in whatever form is appropriate, and to actively invite suggestions as it has probably never been truer than now that we do not have all the answers. And not only that, it might be a good idea to show our appreciation to workers who didn’t get a mention in that magnificent show of appreciation directed – quite deservedly, at the NHS.